UBO declaration: what is it and when do you request one?

In short

  • A UBO declaration is a signed statement from your business customer about who the ultimate beneficial owners (UBOs) are and how ownership and control are arranged.
  • You request the declaration when entering into the relationship, at periodic reviews and when there are signs that the structure has changed.
  • The Wwft does not prescribe a fixed template. The declaration must, however, contain enough information to identify each UBO and understand the structure.
  • A declaration alone is not enough. You check its content against the KvK UBO register and other independent sources, and you keep it up to date.

A UBO declaration is a signed statement from your business customer about who its ultimate beneficial owners are. In Dutch it is called a UBO-verklaring. You request it at the start of the relationship, at periodic reviews and when the structure changes. The declaration is a good starting point, but it is not enough. You always check its content against the KvK UBO register and other independent sources.

You can read what a UBO is in What is a UBO?. This article is about the declaration itself and its place in your KYC process.

What exactly is a UBO declaration?

In a UBO declaration, the customer states in writing who the natural persons are that ultimately own or control it. The customer also explains how that interest is structured. An authorised representative signs the declaration.

The Wwft does not prescribe a fixed template. Institutions usually use their own form, aligned with their policy. That is not a problem, as long as the content is complete and verifiable.

The declaration is different from a UBO extract from the KvK. The extract comes from the UBO register. The declaration comes from the customer and is intended for your own investigation.

When do you request a UBO declaration?

  • when onboarding a new business customer
  • at a periodic review, depending on the risk profile
  • when there are signs of change, such as a share transfer, merger or new director
  • when the UBO register is incomplete or differs from what you know
  • for foreign entities for which no readily accessible register exists

What should it contain?

A useful UBO declaration contains at least:

  • personal details of each UBO: name, date of birth, nationality and country of residence
  • the nature and extent of the interest: shares, voting rights or ownership interest, with percentages
  • how the interest is held: directly, or through which intermediate entities
  • other forms of control, such as agreements between shareholders or veto rights
  • if there is no UBO: an explanation and the details of the pseudo-UBOs from senior management
  • whether a UBO is a politically exposed person (PEP), or a family member or close associate of one
  • a structure chart as an annex where there are several layers
  • name, position and signature of the signatory, with the date
  • a commitment that the customer will report changes in good time

Why a declaration alone is not enough

A UBO declaration is information from the customer about itself. The Wwft asks for more. You must establish the UBO, take reasonable measures to verify their identity and understand the ownership and control structure.

A declaration can be wrong. Sometimes by accident, because the customer does not know the rules well. Sometimes because the information is out of date. And sometimes deliberately, because someone wants to stay out of sight. Preventing that last situation is exactly what UBO research is for.

Therefore check the declaration against independent sources:

  1. The KvK UBO register. Institutions subject to the Wwft can request an extract. Note: the register is also based on what the organisation itself has registered.
  2. The Trade Register. Check the directors, the authority to represent and the legal form.
  3. Articles of association and shareholders' register. These show who holds the shares and which rights are attached to them.
  4. Foreign registers and annual reports, for entities outside the Netherlands.
  5. Identity documents of the UBOs.

If you find discrepancies, ask the customer for an explanation and record it. If the UBO register differs from what you establish, you report this back to the KvK. Unexplained discrepancies can be a reason for enhanced due diligence.

Keeping the declaration up to date

A UBO declaration is a snapshot. Shares are sold, holding companies are set up, directors leave. Keep the information up to date:

  • agree with the customer that they will report changes on their own initiative
  • ask for a confirmation or a new declaration at every periodic review
  • check the UBO register again when there are signs of change
  • keep every version with its date, so that you can later show what you knew and when

From 10 July 2027 the AMLR applies. It also sets requirements for how current and complete UBO information must be. A well maintained file makes that transition easier.

Doing it yourself or outsourcing

Requesting a UBO declaration is simple. Verifying it, asking follow-up questions and keeping it up to date takes more time, especially with many customers or complex structures. Some organisations outsource this work to specialised analysts. You then remain responsible for the policy and the decision on the customer.

Frequently asked questions

Is a UBO declaration mandatory?

The Wwft requires you to establish the UBO and take reasonable measures to verify their identity. A UBO declaration is a common tool for this, but the law does not prescribe a specific form. Many institutions set out in their own policy that they request a declaration.

Is there an official template for the UBO declaration?

The Wwft does not prescribe a fixed template. Institutions usually use their own form, aligned with their policy and risk assessment. What matters more than the format is that the content is complete and verifiable.

Is a UBO extract from the KvK not enough?

No. The UBO register is an important source, but you may not rely on it exclusively. The data is registered by the organisation itself. You combine the extract with the declaration from the customer and other sources.

Who signs the UBO declaration?

Usually someone authorised to represent the organisation, such as a director or a person holding a power of attorney. Check in the Trade Register whether that person has the authority to do so.

How often should I request a new UBO declaration?

That depends on the risk of the customer. With a high risk, you ask for confirmation more often. When there are signs of change, such as a share transfer or restructuring, you ask for a new declaration straight away.

Outsource your UBO research?

BlueMonks collects and verifies UBO information as part of your customer due diligence, with experienced analysts and our own platform Wisdom. You stay in control of every decision.